Importance of Complementary User Entity Controls for Vendor Relationships

Complementary User Entity Controls (CUECs), also known as User Control Considerations (UCCs), are controls that the vendor has included within its system and rely on the user entity (you) to implement in order to achieve the vendor’s control objectives.

In most cases, the control objectives stated in the description can be achieved only if these complementary user entity controls are suitably designed and operating effectively (by you), combined with the controls at the service organization (the vendor).

CUECs are documented within a SOC report in different ways, usually depending on the preference of the vendor and the audit firm performing the SOC review.

Common Placement of Complementary User Entity Controls in a SOC Report

• Specific subsection of the description – You can often find the CUECs listed out in the service description section with details on how exactly they relate to the control objectives laid out in the report.
  
  
• As part of the tested controls section – You can also find the CUECs right in the testing section. They’re usually documented along with the control objectives they align with.

Finding the CUECs in the report is only part of the battle! Understanding what CUECs mean to your organization is critical. It’s crucial to fully understand complementary user entity controls because they outline to you (the intended user of the product or service) the roles, responsibilities and obligations you have in ensuring the stated control objectives are effective for your organization.

Common Examples of CUECs in a SOC Report

• Logical Access:

• Account provisioning
• General IT controls and policies
• Account management

• Separation Procedures:

• Timely account removal
• Regular assessment of accounts

• Authorization Policies and Procedures:

• Policies and procedures that ensure transactions are appropriately authorized and transactions are secure, timely and complete

• Data Transmission Policies and Procedures:

• When sending data, it must be protected by appropriate methods such as encryption
  
  

You’ve Located the CUECs. Now What?

Knowing about CUECs still isn’t enough. As part of your vendor risk management process, you have to map them back to your own policies and procedures to ensure that you have controls in place that properly align with your vendor’s expectations. Part of comprehending a vendor’s value in providing a product or service is making sure you can effectively execute your responsibilities. 

For a full check on your vendor management policy, program and procedures, download our Vendor Management Umbrella infographic series.